The defendant is charged [in count __]
with unlawfully concealing a will. The statute defining this offense reads in
pertinent part as follows:

a person is guilty of unlawfully
concealing a will when, with intent to defraud, (he/she) conceals, secrets,
suppresses, mutilates or destroys a will, codicil or other testamentary
instrument.

For you to find the defendant guilty
of this charge, the state must prove the following elements beyond a reasonable
doubt:

Element 1 - Existence of a willThe first element is that there was a
will, codicil or other testamentary instrument. A will is an instrument by
which one disposes of (his/her) property, to take effect at (his/her) death. <Describe
the alleged document.>

Element 2 - Concealed the willThe second element is that the
defendant concealed, secreted, suppressed or mutilated the <identify document>.

Element 3 - IntentThe third element is that the
defendant acted with the intent to defraud. <See
Intent to Defraud, Instruction 2.3-6.>

Conclusion

In summary, the state must prove
beyond a reasonable doubt that 1) a will, codicil or other testamentary
instrument existed, 2) the defendant <insert specific allegations>, and
3) (he/she) did so with the intent to defraud.

If you unanimously find that the state
has proved beyond a reasonable doubt each of the elements of the crime of
unlawfully concealing a will, then you shall find the defendant guilty. On the
other hand, if you unanimously find that the state has failed to prove beyond a
reasonable doubt any of the elements, you shall then find the defendant not
guilty.